Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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HC quashed customs authorities' orders declining export drawback claims under Section 75 of Customs Act, 1962. Petitioner sought drawbacks for exports where realization of proceeds exceeded stipulated timeframe under Rule 16A. Customs rejected claims citing delayed realization without considering AD-I bank's regularization documents. Court held that AD Category-I banks possess authority to extend time limits for export proceeds realization, not exclusively RBI. Documentary evidence including bank's regularization certificate and export repatriation confirmation required proper examination to determine if receipts fell within extended period. Matter remanded to customs authorities for fresh consideration incorporating all relevant documents and specific reference to bank's extension powers under Rule 16A framework.
HC quashed customs authorities' orders declining export drawback claims under Section 75 of Customs Act, 1962. Petitioner sought drawbacks for exports where realization of proceeds exceeded stipulated timeframe under Rule 16A. Customs rejected claims citing delayed realization without considering AD-I bank's regularization documents. Court held that AD Category-I banks possess authority to extend time limits for export proceeds realization, not exclusively RBI. Documentary evidence including bank's regularization certificate and export repatriation confirmation required proper examination to determine if receipts fell within extended period. Matter remanded to customs authorities for fresh consideration incorporating all relevant documents and specific reference to bank's extension powers under Rule 16A framework.
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